In 2005 a U.S. federal court struck down a motion to teach “intelligent design” along with the federally mandated topic of evolution. Since then, scientists and educators have developed evolution-based curricula to counter the growing movement questioning the validity of evolutionary theory (Education Week, November 16, 2010). In 2008, the Council of Europe “condemned all attempts to bring creationism into Europe’s schools” (USA Today, February 11, 2008).